Nigeria: AML/CTF Regime

Nigeria's standing AML/CTF regime is unchanged this cycle: the Money Laundering (Prevention and Prohibition) Act 2022 and the Terrorism (Prevention and Prohibition) Act 2022 remain the primary legislative basis, with the Nigerian Financial Intelligence Unit, housed within the Central Bank of Nigeria, serving as the financial intelligence unit and the Economic and Financial Crimes Commission as lead enforcement agency. Nigeria was removed from the FATF grey list on 24 October 2025 after achieving Compliant or Largely Compliant status on 37 of the 40 FATF Recommendations, a status that has not altered this cycle. What has moved is institutional preparation: the NFIU trained 100 officials nearly a year after the grey-list exit, with NFIU Chief Executive Officer Hafsat Bakari stating that Nigeria must demonstrate its AML/CFT laws and institutions deliver results, not merely exist on paper, as the country approaches a full FATF Mutual Evaluation expected in 2027. This framing is significant: a full mutual evaluation tests institutional effectiveness, not merely the existence of a compliant legal framework, which is a materially higher bar than the increased-monitoring follow-up process Nigeria has just exited.

Outlook

The 2027 FATF Mutual Evaluation is the fixed point against which Nigeria's current capacity-building activity should be read. Continued NFIU and EFCC training and stocktaking activity between now and that evaluation is the clearest indicator of whether Nigeria's delisted status will be sustained under the more demanding effectiveness-based scrutiny a full mutual evaluation applies.